Planned Parenthood of
Northern New England, along with several other women’s health centers, filed a
complaint stating that the New Hampshire Parental Notification Act was unconstitutional.The New
Hampshire law required doctors to delay a teenager's
abortion until 48 hours after a parent was notified, but it lacked a medical
emergency exception to protect the teenager's health.The lower courts struck down the law because
of this “undue burden.”The case was
appealed to the Supreme Court by State Attorney General, Kelly Ayotte.

The decision, written by Justice Sandra Day O’Connor,
established a few main points: states have a right to require parental
involvement when a teen wishes to terminate her pregnancy and states cannot
restrict abortions when it is crucial to the health of the woman.

However, the Court felt that invalidating the
entire state law was not necessary, as long as it was not presenting an “undue
burden” to teenagers. The Supreme Court sent the case back down to a lower court to decide whether or not the state legislature meant to include a health exemption to the law.